De Vivo v. Commissioner of Social Security

Filing 18

STIPULATION and ORDER GRANTING the parties' request for an extension of time to 6/27/2016 for receipt of defendant's response to plaintiff's motion for summary judgment, with all other deadlines extended accordingly. Order signed by Magistrate Judge Erica P. Grosjean on 5/16/2016. (Rooney, M)

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PHILLIP A. TALBERT
Acting United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
ROYA MASSOUMI, CSBN 242697
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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MAX M. DE VIVO

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Plaintiff,
vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

Case No.: 1:15-CV-01332-EPG
STIPULATION AND ORDER FOR
EXTENSION OF TIME FOR DEFENDANT
TO FILE OPPOSITION TO PLAINTIFF’S
MOTION FOR SUMMARY JUDGMENT

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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,

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that the time for responding to Plaintiff’s Motion for Summary Judgment be extended from May

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27, 2016 to June 27, 2016. This is Defendant’s first request for extension. Defendant

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respectfully requests additional time following recent reassignment of the case in order to

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adequately research and analyze the issues presented by Plaintiff. In addition, counsel for

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Defendant will be on a scheduled vacation from May 26th through May 31st, 2016 – which

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conflicts with the current deadline. Defendant makes this request in good faith with no intention

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to unduly delay the proceedings.

Stip. & Order to Extend 1:15-CV-01332-EPG

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The parties further stipulate that the Court’s Scheduling Order shall be modified
accordingly.

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Respectfully submitted,

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Dated: May 12, 2016

/s/ *Monica Perales
(*as authorized by email on May 11, 2016)
MONICA PERALES
Attorney for Plaintiff

Dated: May 12, 2016

PHILLIP A. TALBERT
Acting United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX,
Social Security Administration

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By:

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/s/ Roya Massoumi
ROYA MASSOUMI
Special Assistant U.S. Attorney
Attorneys for Defendant
Of Counsel:
TINA L. NAICKER
Assistant Regional Counsel
Attorneys for Defendant

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Stip. & Order to Extend 1:15-CV-01332-EPG

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ORDER

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Based on the above stipulation, and good cause appearing therein, the Court grants

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Defendant an extension of time to file her opposition to Plaintiff’s opening brief. Defendant’s

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opposition brief shall be filed no later than June 27, 2016. Plaintiff may file her reply brief no

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later than July 12, 2016.

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IT IS SO ORDERED.

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Dated:

May 16, 2016

/s/

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UNITED STATES MAGISTRATE JUDGE

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Stip. & Order to Extend 1:15-CV-01332-EPG

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